Fraud Remediation
Fraud Incident Remediation Plan
Response & Prevention Strategy
Summary & Strategic Framework
This comprehensive remediation plan addresses the recent fraud incident through a multi-layered approach encompassing physical security, controls and personnel management.
🎯 Our Response Strategy
The plan establishes immediate protective measures while building sustainable long-term fraud prevention capabilities across the organization. Our response focuses on three core pillars:
DETECT
Monitoring to identify suspicious activities in real-time
PREVENT
Multi-layered controls create barriers against fraudulent behavior
RESPOND
Swift action and accountability reinforce zero-tolerance culture
What You'll Learn:
- Physical security enhancements
- Quality monitoring controls
- Personnel management strategies
- Oversight and accountability structures
- Implementation roadmap and ownership
Physical Security Enhancement
Strengthening our physical security perimeter creates the first line of defense against unauthorized items and reinforces our commitment to a controlled, secure work environment.
🔐 Production Entrance Security Optimization
Metal Detection
We are implementing the use of metal detectors at all entrances and exits across all three sites.
Visual Checks
In addition to metal detection, guards will carry out thorough visual checks to identify any other prohibited items.
- Scanning items that could be concealed in easily accessible areas
- Pat-downs on jackets to ensure no items are missed
- Extra layer of protection for a safe and compliant environment
👁️ Strategic Workspace Configuration
Visibility is a powerful deterrent. By restricting wall-adjacent, low-visibility workstations to leadership personnel, we eliminate blind spots that could enable unobserved inappropriate activity.
⏱️ Reduction of Time on the Floor
By limiting time in the production area, we reduce the risk of disruptive behaviors and maintain a more controlled environment.
Quality Monitoring Controls
Enhance our quality monitoring processes to better identify fraud, ensuring that we capture patterns and behaviors that might otherwise go unnoticed.
🎯 Nexidia Voice Analytics
We are adding query-based triggers on Nexidia to flag concerning communication patterns.
Monitored Fraud Indicators:
Implementation Protocol:
Deploy trigger keywords, review and escalate flagged calls for further investigation
🔍 High-Risk Contact Types Monitoring
Additional audits focused on high-risk contact types to proactively identify and mitigate risks.
Financial Audits
Verify accuracy and legitimacy of financial transactions
Credit Card Monitoring
Detect potential unauthorized activities
Profile Changes
Identify unusual or unauthorized modifications
Credit Audits
Ensure all credits are properly applied
Long Call Audits
Assess quality and integrity of interactions
⚡ Spark Recent Accounts Intelligence
The Spark Recent Accounts monitoring addresses this gap by requiring teammate justification for RESEARCH account access.
Immediate Actions:
- Performance Analysts conduct random audits across all team members
- Target spot checks on teammates based on behavioral risk assessments
- Verify account opening justifications and cross-reference with interaction records
- Validate documentation completeness for research-only account access
Ongoing Monitoring:
- Escalate unexplained access within 24 hours for additional investigation
Frequency, Reporting & Escalation
To ensure consistency, traceability, and timely response, all fraud-related audits and monitoring activities follow a defined frequency, reporting cadence, and escalation process.
📅 Audit Frequency & Monitoring Cadence
Keyword-triggered reviews conducted daily
Contact type audits conducted weekly
Weekly with daily targeted spot checks
Reviewed weekly or immediately if flagged
📊 Reporting Structure
- All audit findings documented and consolidated into weekly fraud monitoring summary
- Material findings and emerging risk patterns escalated to PDEV and PMAX leadership
- Trends, repeat behaviors, and control effectiveness reviewed during Monthly Site Risk Assessment Forum
🚨 Escalation Process
Review & Documentation
Initial keyword hits or audit findings are reviewed and documented by Performance Analysts or assigned reviewers
Operations Escalation
Findings with potential policy violations, repeated behaviors, or elevated risk are escalated to Operations leadership within 24 hours
Formal Investigation
Confirmed or high-risk cases are escalated for formal investigation, including expanded call reviews, system access checks, and personnel review
Disciplinary Action & Client Notification
Substantiated fraud, breaches, or confirmed misconduct result in formal HR action, up to and including termination, in accordance with ePerformax policy. Validated incidents are communicated to PayPal per agreed protocols.
Personnel Management
This section addresses fraud risk through additional screening, continuous behavioral monitoring, and cultural reinforcement that makes integrity the default choice.
🎯 Enhanced Recruitment & Onboarding
While experience brings valuable skills, it also brings knowledge of system vulnerabilities. Our enhanced screening process identifies these candidates for additional oversight without discriminatory exclusion.
Program Interview Protocol Enhancement:
✨ "Do the Right Thing" Campaign
Our "Do the Right Thing" campaign is actively transforming fraud prevention from a policy requirement into a shared organizational value.
Prosecution Awareness
Broadcasting video evidence of legal consequences associated with fraud
Whistleblower Protection
Established reporting mechanisms and confidentiality guarantees
Reward Program
Incentivizing proactive reporting of suspicious activities
Continuous Reinforcement
Regular communications emphasizing ethical decision-making
Management Oversight & Accountability
📋 Monthly Site Risk Assessment Forum
Monthly risk meetings bring together Operations, Training, and Management perspectives to evaluate control effectiveness and emerging threat patterns.
Meeting Framework:
- Schedule: Designated day of each month
- Attendees: Operations leadership, Training team, Management representatives
- Agenda: Action plan effectiveness review, emerging threat discussion
- Deliverable: Documented action items and ownership
👥 Coach Risk Assessment Program
Front-line coaches possess unique insights into employee behavior patterns. Our risk assessment transforms these observations into actionable intelligence through monthly evaluations.
13-Point Assessment Criteria:
Prior call center experience and associated vulnerability knowledge
Behavioral pattern anomalies or unexplained performance fluctuations
Personal financial stress indicators shared through casual conversation
Engagement level changes or withdrawal from team activities
Assessment Protocol:
Implementation Roadmap & Ownership
The following action matrix establishes ownership and timelines for all remediation initiatives.
Conclusion & Commitment
This comprehensive remediation plan represents our commitment to transforming a security incident into an opportunity for organizational strengthening.
🎯 Our Commitment
By addressing vulnerabilities across physical security and personnel management, we are building a resilient fraud prevention ecosystem that extends far beyond addressing the immediate incident.
Multi-Layered Approach Benefits:
- No single point of failure can compromise our security posture
- Multiple opportunities for detection before minor issues escalate
- Sustainable long-term fraud prevention capabilities
- Culture of integrity and accountability
Core Pillars Recap:
Physical Security
Metal detection, visual checks, workspace configuration
Quality Monitoring
Voice analytics, high-risk audits, account intelligence
Personnel Management
Enhanced screening, cultural campaigns, risk assessments
Oversight & Accountability
Monthly forums, coach assessments, clear ownership
Complete Your Training
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What You've Learned:
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